Case Study - Plains All American Pipeline Company (Plains)

E2 has provided environmental consulting services to Plains All American Pipeline Company (Plains) and predecessors Pacific Energy Partners and ARCO Pipeline for over a decade. Activities have covered broad areas from air permitting, spill prevention planning, to stormwater, remediation and due diligence. E2 is currently in the environmental planning and permitting process for the construction of a 350,000 barrel per day crude oil import terminal in the Port of Los Angeles (POLA) that will serve as the only inner harbor crude oil facility (Project) capable of offloading Very Large Crude Carriers (VLCCs). This marine terminal, which is a critical component of the entire West Coasts energy infrastructure, is proposed to be built at Berth 408 of Pier 400. Plains is proposing to construct up to 12 new crude oil storage tanks, as well as 7 miles of new crude oil transport pipeline. The pipeline will connect crude oil supertankers to the new storage tanks, which would then connect to other existing infrastructure and refineries in the Los Angeles basin. The construction of 12 new tanks and 7 miles of pipeline has triggered CEQA/NEPA requirements, including the preparation of a Supplemental Environmental Impact Statement/Report (SEIS/SEIR). POLA is the lead agency and has primary ownership of the SEIS/SEIR. E2 served as the lead consultant for the project proponent, Plains, in the development of NEPA and CEQA documentation.

In our capacity as lead consultant, E2 has prepared project descriptions, baseline analyses and impact studies in several areas including air quality, water quality, and subsurface contamination. In particular, air quality was a challenge for the project given a baseline of zero existing emissions and significant local concerns with regard to impacts of diesel particulate matter emissions in the neighboring communities of San Pedro and Wilmington. A project health risk analysis was also developed by E2 as part of the SEIS/SEIR process. POLA Board of Harbor Commissioners certified the SEIS/SEIR in November 2008.

In addition to CEQA/NEPA services, E2 is supporting ongoing environmental program development efforts for this project, including compliance, permit condition negotiation, evaluation of methodologies for Plains to comply with program requirements, and tools for compliance demonstration. In particular, this facility has faced unique air quality permitting constraints in that the local South Coast Air Quality Management District (SCAQMD) regulations require consideration of vessel emissions, traditionally a mobile source, as part of the stationary source permits. Additionally, E2 is coordinating with various federal, state and local public agencies to ensure compliance with the water quality standards of the City of Los Angeles, Regional Water Quality Control Board (RWQCB) and various other public agencies.

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